r 

PVCC 

PIEDMONT VIRGINIA 

COMMUNITY COLLEGE 

Piedmont Virginia Community Cotlege 

501 College Dr. 

Charlottesville, VA 22902 

February 5, 2016 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

501 College Drive 

Charlottesville, Virginia 22902-7589 

434-961-3900 

4334-961-5200 

V/TIY 434-977-4265 

www.pvcc.edu 

RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from 14 C.P.R. 45.23(b); 14 CFR Part 21; 14 CFR 61.113 (a) 

& (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 

91.203(a) & (b); 91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b). 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the 

Reform Act) and 14 C.P.R. Part 11, PIEDMONT VIRGINIA COMMUNITY COLLEGE 

("the applicant"), operator of Small Unmanned Aircraft Systems ("sUASs") equipped to 

conduct sUAS flight training, hereby applies for an exemption from the listed Federal 

Aviation Regulations ("FARs") to allow commercial operation of its sUASs, so long as 

such operations are conducted within and under the conditions outlined herein or as may 

be established by the FAA as required by Section 333. 

As described more fully below, the requested exemption would permit the 

operation of small, unmanned, and relatively inexpensive sUAS under controlled 

conditions in airspace that is 1) limited, 2) predetermined, 3) controlled as to access, and 

4) would provide safety enhancements to the already safe operations in emergency 

services, public safety, and commercial operations or aerial data collection and remote 

sensing presently using conventional aircraft. Approval of this exemption would thereby 

enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) 

responsibilities to" ... establish requirements for the safe operation of such aircraft systems 

in the national airspace system." Section 333(c) of the Reform Act. 

The name and address of the applicant is: 

PIEDMONT VIRGINIA COMMUNITY COLLEGE 

Attn: Frank Friedman 

Ph: 434.961.5200 

Email: ffriedman @pvcc.edu 
PIEDMONT VIRGINIA 

COMMUNITY COLLEGE 

Address: 501 College Dr. 

Charlottesville, VA 22902 

Regulations from which the exemption is requested: 

14 CFR Part 21 

14 C.F.R. 45.23(b) 

14 CFR 61.113 (a) & (b) 

14 C.F.R. 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 C.F.R. 91.103 

14 C.F.R. 91.109 

14 C.F. R. 91.119 

14 C.F.R. 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CFR 417 (a) & (b) 

This exemption application is expressly submitted to fulfill Congress' goal in 

passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of 

Transportation to consider whether certain unmanned aircraft systems may operate safely 

in the national airspace system (NAS) before completion of the rulemaking required under 

Section 332 of the Reform Act. In making this determination, the Secretary is required to 

determine which types of UASs do not create a hazard to users of the NAS or the public or 

pose a threat to national security in light of the following: 

• The UAS's size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator. 

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles "may 

operate safely in the national airspace system, the Secretary shall establish requirements 

for the safe operation of such aircraft in the national airspace system." Id. §333(c) 

(emphasis added). 1 

1 Applicant interprets this provision to place the duty on the Administrator to not only process applications 

for exemptions under section 333, but for the Administrator to craft conditions for the safe operation of the 

UAS, if it should be determined that the conditions set forth herein do not fulfill the statutory requirements 

for approval. 

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COMMUNITY COLLEGE 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. 

This statutory authority by its terms includes exempting civil aircraft, as the term is defined 

under §40101 of the Act, which includes sUASs, from the requirement that all civil aircraft 

must have a current airworthiness certificate. 

The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of this 

title if the Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) 

See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1). 

The applicant's sUAS (Appendix 1) are fixed wing androtorcraft, weighing 55 or fewer 

lbs. including payload. They operate under normal conditions at a speed of no more than 

25 to 35 knots and have the capability to hover and move in the vertical and horizontal 

plane simultaneously and move in the horizontal plane. They will operate only in line of 

sight and will operate only within the sterile area described in the Unmanned Aircraft 

Systems Operations Manual(s), attached as Appendix 2 (hereinafter "the Manuals"). Such 

operations insure that the sUAS does "not create a hazard to users of the national airspace 

system or the public. "2 

Given the small size of the sUASs involved and the restricted sterile environment 

within which they will operate, the applicant falls squarely within that zone of safety (an 

equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, 

allow commercial operations of UASs to commence immediately. Also due to the size of 

the UASs and the restricted areas in which the relevant sUASs will operate, approval of 

the application presents no national security issue. Given the clear direction in Section 333 

of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the 

strong equivalent level of safety surrounding the proposed operations, and the significant 

public benefit, including enhanced safety, reduction in environmental impacts, including 

reduced emissions associated with allowing UASs for training of emergency services, 

public safety personnel and commercial operators for aerial data collection and remote 

sensing, the granting of the requested exemptions is in the public interest. Accordingly, the 

applicant respectfully requests that the FAA grant the requested exemption without delay. 

Background Information 

The applicant is in the business of training emergency services, public safety and 

commercial operators for aerial data collection and remote sensing. The applicant's clients 

look to the applicant for safe operations of sUAS. The applicant has developed specific 

safe UAV operational procedures. Increasingly, the applicant has clients looking for sUAS 

services for aerial data collection and remote sensing. 

2 Reform Act Section 333 (b). 

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Operations performed by the applicant include: 

1. Training of emergency services s U AS operators for aerial data collection and remote 

sensing. 

2. Training of public safety s U AS operators for aerial data collection and remote 

sensing. 

3. Training of commercial s U AS operators for aerial data collection and remote 

sensing. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The applicant proposes that the exemption requested herein apply to civil aircraft that 

have the characteristics and that operate within the limitations listed herein. These 

limitations provide for at least an equivalent or even higher level of safety to operations 

under the current regulatory structure because the proposed operations represent a safety 

enhancement to the already safe aerial data collection and remote sensing conducted with 

conventional aircraft. 

These limitations and conditions to which the applicant agrees to be bound when 

conducting commercial operations under an FAA issued exemption include: 

1. The sUAS will weigh less than 55lbs. 

2. Flights will be operated within line of sight of a pilot and/or observer. 

3. Maximum total flight time for each operational flight will be 30 minutes. Flights 

will be terminated at 25% battery power reserve should that occur prior to the 30 

minute limit. 

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more 

than 200 feet above an elevated platform from which flight is planned. 

5. Minimum crew for each operation will consist of the sUAS Pilot and the Visual 

Observer. 

6. The sUAS pilot-in-command (PIC) will hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC will also hold 

a current FAA airman medical certificate or a valid U.S. driver's license issued by 

a state, the District of Columbia, Puerto Rico, a territory, a possession, or the 

Federal government 

7. If a pilot certificate holder other than the sUAS Pilot, who possess the necessary 

PIC qualifications, is also present on site, that person can also be designated as PIC. 

8. The sUAS will only operate within defined boundaries as outlined in Section 8.4 

of the Manual. 

9. A briefing will be conducted in regard to the planned sUAS operations prior to each 

mission. It will be mandatory that all personnel who will be performing duties 

within the boundaries of the safety perimeter be present for this briefing. 

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10. The operator will file a FAA Form 7711-1, or its equivalent, as modified in light of 

the requested exemption, with the appropriate Flight Standards District Office 

(FSDO). 

11. The operator will obtain the consent of all persons involved in the mission and 

ensure that only consenting persons will be allowed within 100 feet of the flight 

operation, and this radius may be reduced to 30 feet based upon an equivalent level 

of safety determination, as required by Section 8.4 of the Manual. With the 

advanced permission of the relevant FSDO, operations at closer range can be 

approved. 

12. The operator will submit a written Plan of Activities to the FSDO three days before 

the proposed mission as required in Section 8.1 of the Manual. Items will include: 

a. Dates and times for all flights; 

b. Name and phone number of the operator for the UAS mission conducted 

under this petition of exemption; 

c. Make, model, and serial or N-number of UAS to be used; 

d. Name and certificate number of UAS PICs involved in the mission; 

e. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the mission; 

f. The list of those who gave permission made available to the inspector upon 

request; 

g. Signature of exemption-holder or representative; and 

h. A description of the flight activity, including maps or diagrams of any area, 

city, town, county, and/or state over which the mission will be conducted 

and the altitudes essential to accomplish the operation. 

13. Pilot and observer will have been trained in operation of UAS generally and 

received up-to-date information on the particular UAS to be operated as required 

in Sections 7.4 and 7.5 of the Manual. 

14. Observer and pilot will at all times be able to communicate by voice. 

15. Written and/or oral permission from the relevant property holders will be obtained. 

16. All required permissions and permits will be obtained from territorial, state, county 

or city jurisdictions, including local law enforcement, fire, or other appropriate 

governmental agencies. 

17. If the sUAS loses communications or loses its GPS signal, the UAS will have the 

capability to return to a pre-determined location within the Security Perimeter and 

land. 

18. The sUAS will have the capability to abort a flight in case of unpredicted obstacles 

or emergencies. 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural 

requirements for the issuance of airworthiness certificates as required by FAR §91.203 (a) 

(1). Given the size and limited operating area associated with the aircraft to be utilized by 

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the Applicant, an exemption from Part 21 Subpart H meets the requirements of an 

equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal 

Aviation Act (49 U.S.C.§44701 (f)) and Section 333 ofthe Reform Act both authorize the 

FAA to exempt aircraft from the requirement for an airworthiness certificate, upon 

consideration of the size, weight, speed, operational capability, and proximity to airports 

and populated areas of the particular UAS. In all cases, an analysis of these criteria 

demonstrates that the U AS operated without an airworthiness certificate, in the restricted 

environment and under the conditions proposed will be at least as safe, or safer, than a 

conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate 

without the restrictions and conditions proposed. 

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither 

a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates 

exclusively within a secured area as set out in the Manual. Unlike other civil aircraft, 

operations under this exemption will be tightly controlled and monitored by both the 

operator and observer, pursuant to the Manual's policies, and under and in compliance with 

local public safety requirements, to provide security for the area of operation as is now 

done with conventional manned rotorcraft and/or fixed wing aircraft. The FAA will have 

advance notice of all operations. These safety enhancements, which already apply to civil 

aircraft operated in connection with emergency, public safety and commercial aerial data 

collection and remote sensing, provide a greater degree of safety to the public and property 

owners than conventional operations conducted with airworthiness certificates issued 

under 14 C.P.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates 

that there is no credible threat to national security posed by the UAS, due to its size, speed 

of operation, location of operation, lack of explosive materials or flammable liquid fuels, 

and inability to carry a substantial external load. 

14 C.F.R. § 45.23 (b). Marking of the Aircraft 

The regulation requires: 

When marks include only the Roman capital letter "N" and the registration 

number is displayed on limited, restricted or light-sport category aircraft or 

experimental or provisionally certificated aircraft, the operator must also 

display on that aircraft near each entrance to the cabin, cockpit, or pilot 

station, in letters not less than 2 inches nor more than 6 inches high, the 

words "limited," "restricted," "light-sport," "experimental," or 

"provisional," as applicable. 

Even though the UAS will have no airworthiness certificate, an exemption may be 

needed as the UAS will have no entrance to a cabin, cockpit or pilot station on which the 

word "Experimental" can be placed. Given the size of the sUAV, two-inch lettering will 

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be impossible. The word "Experimental" will be placed on the fuselage in compliance with 

§45.29 (f). 

The equivalent level of safety will be provided by having the sUAV marked on its 

fuselage as required by §45.29 (f) where the pilot, observer and others working with the 

sUAV will see the identification of the UAS as "Experimental." The FAA has issued the 

following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 

10167A. 

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in 

Command. 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. 

Because the UAS will not carry a pilot or passengers, the proposed operations can achieve 

the equivalent level of safety of current operations by requiring the PIC operating the 

aircraft to have a pilot's certificate operate this small UAS. Unlike a conventional aircraft 

that carries the pilot and passengers, the sUAS is remotely controlled with no living thing 

on board. The area of operation is controlled and restricted, and all flights are planned and 

coordinated in advance as set forth in the Manual. The level of safety provided by the 

requirements included in the Manual exceeds that provided by a single individual holding 

a commercial pilot's certificate operating a conventional aircraft. The risks associated with 

the operation of the sUAS are so diminished from the level of risk associated with 

commercial operations contemplated by Part 61 when drafted, that allowing operations of 

the sUAS as requested by a pilot's certificate as the PIC exceeds the present level of safety 

achieved by 14 C.P.R. §61.113 (a) & (b). 

14 C.F.R. §91.7(a): Civil aircraft airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in 

airworthy condition. As there will be no airworthiness certificate issued for the aircraft, 

should this exemption be granted, no FAA regulatory standard will exist for determining 

airworthiness. Given the size of the aircraft and the requirements contained in the Manual 

for maintenance and use of safety checklists prior to each flight, as set forth in Sections 9.1 

and 9.6, an equivalent level of safety will be provided. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides: 

No person may operate a U.S.-registered civil aircraft ... (2) For which an 

Airplane or Rotorcraft Flight Manual is not required by §21.5 of this 

chapter, unless there is available in the aircraft a current approved airplane 

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or Rotorcraft Flight Manual, approved manual material, markings, and 

placards, or any combination thereof. 

The sUAS, given its size and configuration has no ability or place to carry such a 

flight manual on the aircraft, not only because there is no pilot on board, but because there 

is no room or capacity to carry such an item on the aircraft. 

The equivalent level of safety will be maintained by keeping the flight manual at 

the ground control point where the pilot flying the sUAS will have immediate access to it. 

The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. 

14 C.F.R. § 91.103: Preflight action 

This regulation requires each pilot in command to take certain actions before flight 

to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be 

provided for the aircraft, an exemption will be needed. An equivalent level of safety will 

be provided as set forth in Sections 8 and 9 of the Manual. The PIC will take all actions 

including reviewing weather, flight battery requirements, landing and takeoff distances, 

and aircraft performance data before initiation of flight. 

14 C.F.R. §91.109: Flight instruction 

Section 91.103 provides that no person may operate a civil aircraft (except a 

manned free balloon) that is being used for flight instruction unless that aircraft has fully 

functioning dual controls. 

sUASs and remotely piloted aircraft, by their design do not have fully functional 

dual controls. Flight control is accomplished through the use of a control box that 

communicates with the aircraft via radio communications. The FAA has approved 

exemptions for flight training without fully functional dual controls for a number of aircraft 

and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A. 

The equivalent level of safety provided by the fact that neither a pilot nor passengers will 

be carried in the aircraft and by the size and speed of the aircraft. 

14 C.F.R. §91.119: Minimum safe altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 

91.119( d) allows helicopters to be operated at less than the minimums prescribed, provided 

the person operating the helicopter complies with any route or altitudes prescribed for 

helicopters by the FAA. As this exemption is for a s U AS that is a helicopter and the 

exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 

above an elevated platform from which operation is planned, an exemption may be needed 

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to allow such operations. As set forth herein, except for the limited conditions stated in the 

Manual, the UAS will never operate at higher than 400 AGL. It will, however, be operated 

in a restricted area with a security perimeter, where buildings and people will not be 

exposed to operations without their pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, and speed of 

the UAS as well as the location where it is operated. No flight will be taken without the 

permission of the property owner or local officials. Because of the advance notice to the 

property owner and participants in the mission, all affected individuals will be aware of the 

planned flight operations as set forth in Section 6.2, 8.1, and 8.2 of the Manual. Compared 

to flight operations with aircraft or rotorcraft weighing far more than the maximum 55lbs. 

proposed herein and the lack of flammable fuel, any risk associated with these operations 

is far less than those presently presented with conventional aircraft operating at or below 

500 AGL by emergency, public safety and commercial aerial data collection and remote 

sensing. In addition, the low-altitude operations of the sUAS will ensure separation 

between these small UAS operations and the operations of conventional aircraft that must 

comply with Section 91.119. 

14 C.F.R. §91.121 Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising 

altitude by reference to an altimeter that is set " ... to the elevation of the departure airport 

or an appropriate altimeter setting available before departure." As the sUAS may not have 

a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. 

An equivalent level of safety will be achieved by the operator, pursuant to the Manual and 

safety checklist, confirming the altitude of the launch site shown on the GPS altitude 

indicator before flight. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane 

under VFR conditions unless (considering wind and forecast weather conditions) there is 

enough fuel to fly to the first point of intended landing, and, assuming normal cruising 

speed- (1) During the day, to fly after that for at least 30 minutes; or (2) at night, to fly 

after that for at least 45 minutes." 

The battery powering the sUAS provides approximately 30 minutes of powered 

flight. To meet the 30-minute reserve requirement in 14 CFR §91.151, sUAS flights would 

be limited to approximately 20 minutes in length. Given the limitations on the UAS's 

proposed flight area and the location of its proposed operations within a predetermined 

area, a longer time frame for flight in daylight or night VFR conditions is reasonable. 

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Applicant believes that an exemption from 14 CFR §91.151(a) falls within the 

scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation 

to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly 

controlled area where only people and property owners or official representatives who have 

signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender 

the type of risks that Section 91.151(a) was intended to alleviate given the size and speed 

of the small UAS. Additionally, limiting sUAS flights to 20 minutes would greatly reduce 

the utility for which the exemption will be granted. 

Applicant believes that an equivalent level of safety can be achieved by limiting 

flights to 20 minutes or 25% of battery power whichever happens first. This restriction 

would be more than adequate to return the s UAS to its planned landing zone from anywhere 

in its limited operating area. 

Similar exemptions have been granted to other operations, including Exemptions 

2689F, 5745, 10673, and 10808. 

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in pertinent part: 

(a) Except as provided in § 91.715, no person may operate a civil aircraft 

unless it has within it the following: 

(1) An appropriate and current airworthiness certificate .... 

(b) No person may operate a civil aircraft unless the airworthiness certificate 

required by paragraph (a) of this section or a special flight authorization 

issued under §91.715 is displayed at the cabin or cockpit entrance so that it 

is legible to passengers or crew. 

The UAS fully loaded weighs no more than 55 lbs and is operated without an 

onboard pilot. As such, there is no ability or place to carry certification and registration 

documents or to display them on the sUAS. 

An equivalent level of safety will be achieved by keeping these documents at the 

ground control point where the pilot flying the sUAS will have immediate access to them, 

to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions 

to this regulation. A representative sample of other exceptions includes Exemption Nos. 

9565,9665,9789, 9789A, 9797, 9797A, 9816A, and 10700. 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections 

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These regulations require that an aircraft operator or owner "shall have that aircraft 

inspected as prescribed in subpart E of this part and shall between required inspections, 

except as provided in paragraph (c) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter. .. ," and others shall inspect or maintain the aircraft in 

compliance with Part 43. 

Given that these sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to the applicant. Maintenance will be accomplished 

by the operator pursuant to the flight manual and operating handbook as referenced in the 

Manual (See Sections 8.6 and 9). An equivalent level of safety will be achieved because 

these small UASs are very limited in size and will carry a small payload and operate only 

in restricted areas for limited periods of time. If mechanical issues arise the UAS can land 

immediately and will be operating from no higher than 400 feet AGL. As provided in the 

Manual, the operator will ensure that the UAS is in working order prior to initiating flight, 

perform required maintenance, and keep a log of any maintenance performed. Moreover, 

the operator is the person most familiar with the aircraft and best suited to maintain the 

aircraft in an airworthy condition to provide the equivalent level of safety. 

Pursuant to 14 C.P.R. Part 11, the following summary is provided for publication 

in the Federal Register, should it be determined that publication is needed: 

Applicant seeks an exemption from the following rules: 

14 C.P.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.P.R. §§ 61.113( a) & 

(b);91.7 (a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) 

and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & 

(b) to operate commercially a small unmanned vehicle (55lbs or less) in motion 

picture and television operations. 

Approval of exemptions allowing commercial operations of sUASs in aerial data 

collection and remote sensing will enhance safety by reducing risk. Conventional aerial 

data collection and remote sensing, using jet or piston power aircraft, operate at extremely 

low altitudes just feet from the infrastructure being inspected and in extreme proximity to 

people and structures; and present the risks associated with vehicles that weigh in the 

neighborhood of 4,000lbs, carrying large amounts of jet A or other fuel. Such aircraft must 

fly to and from the work location. In contrast, a sUAS weighing fewer than 55 lbs. and 

powered by batteries eliminates virtually all of that risk given the reduced mass and lack 

of combustible fuel carried on board. The sUAS is carried to the worksite and not flown. 

The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks 

associated with manned aircraft flights. 

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The operation of small UASs, weighing less than 55 lbs., conducted in the strict 

conditions outlined above, will provide an equivalent level of safety supporting the grant 

of the exemptions requested herein, including exempting the applicant from the 

requirements of Part 21 and allowing commercial operations. These lightweight aircraft 

operate at slow speeds, close to the ground, and in a sterile environment and, as a result, 

are far safer than conventional operations conducted with turbine helicopters operating in 

close proximity to the ground and people. 

Privacy 

All flights will occur over private or controlled access property with the property owner's 

prior consent and knowledge. remote sensing 

services. public will be performed for people 

who have also consented for work to be performed or otherwise have agreed to be in the 

area where U AS flight will take place. 

Conclusion 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 - size, 

weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security - provide more than adequate 

justification for the grant of the requested exemptions allowing commercial operation of 

applicant's UAS for training of emergency services, public safety and commercial 

operations for aerial data collection and remote sensing pursuant to the Manual appended 

hereto. 

Sincerely, 

Frank Friedrnan, President 

Piedmont Virginia Community College 

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Appendix 1 

1.1 - DJI Phantom Inspire 1 

1.2 - DJI Phantom 3 Pro 

1.3 - Action Drone AD1 

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1.4 - ProDrone Byrd 

1.5 - UA V Solutions Phoenix ACE LE Pro 

1.5 - HoneyComb AgDrone 

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1.6 - Precisionhawk Lancaster 

1.7- Aerialtronics Zenith 

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1.8 - Pulse Aerospace Vapor55 

1.8- C-Astral Bramor 

1.9 - UA V Factory Penguin BE 

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Appendix 2 

Please see the attached: 

s U AS Operating Manual 

sUAS Pre-Flight Safety Checklist 

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Operations Manual 

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Unmanned Aircraft Systems Operations Manual 

9.7 OTHER ....................................................................................................................... 13 

iii 
Unmanned Aircraft Systems Operations Manual 

operations with the need to accomplish the mission while maintaining public 

privacy and the freedom from intrusion. 

4. Definitions 

1. Aircraft: any contrivance invented, used, or designed to navigate, or fly in, the air. 

2. Airport: a landing area used regularly by aircraft for receiving or discharging 

passengers or cargo. 

3. Civil aircraft: an aircraft except a public aircraft. 

4. Landing area: a place on land or water, including an airport or intermediate landing 

field, used, or intended to be used, for the takeoff and landing of aircraft, even when 

facilities are not provided for sheltering, servicing, or repairing aircraft, or for 

receiving or discharging passengers or cargo. 

5. Administration 

5.1 Operations Manual 

1. The policies and procedures contained in this manual are issued by PIEDMONT 

VIRGINIA COMMUNITY COLLEGE. As such it is an official business document 

of PIEDMONT VIRGINIA COMMUNITY COLLEGE. 

2. This manual is not intended to be all-inclusive, but as a supplement to other 

company guidelines, Federal Aviation Administration regulations, pre-flight safety 

checklists, aircraft manufacturers' approved flight manual, etc. 

3. This manual is written to address UAS operations as they existed when it was 

drafted. Equipment, personnel, environment (internal and external), etc., change 

over time. The management of change involves a systematic approach to 

monitoring organizational change and is a critical part of the risk management 

process. Given this, it is essential that this manual be continually updated as 

necessary. The entire manual must be reviewed, at a minimum, annually to assure 

it is up to date. Any changes to the manual will be communicated as currently 

dictated by company policy. 

4. A copy of the manual (electronic and/or paper) is issued to every person having 

UAS responsibilities. 

5.2 Organization 

1. The UAS unit is comprised of those personnel approved by PIEDMONT 

VIRGINIA COMMUNITY COLLEGE and includes operators, observers and 

others deemed necessary and have assignment as part of the UAS crew. 

2. Assignment to the UAS crew is carefully selected by PIEDMONT VIRGINIA 

COMMUNITY COLLEGE from specially trained staff members of PIEDMONT 

VIRGINIA COMMUNITY COLLEGE with knowledge of the airspace within 

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Unmanned Aircraft Systems Operations Manual 

b. An observer's primary duty is to operate the UAS's equipment including 

cameras, FLIR, radio communications with other crew members and 

property owners as well as be an observer for anything that may affect the 

operator's primary duty (see and avoid). 

c. The UAS Coordinator maintains a file for each observer, which includes 

copies of training records, UAS incidents, etc. 

5.4 Facilities 

1. UAS operations are housed and maintained at a facility designated by PIEDMONT 

VIRGINIA COMMUNITY COLLEGE. 

2. Personnel must not leave the designated facility without making sure the UAS 

equipment is secured. 

3. All personnel are equally responsible for maintaining the facility in a neat, clean 

and orderly fashion. 

5.5 Scheduling 

1. To facilitate the broad use of the UAS, it shall be made available to all UAS flight 

crew members. 

2. To maintain a level of proficiency with the UAS, operators are required, as part of 

their acceptance into the UAS flight crew, to attend training every two months. 

Training is coordinated through the UAS flight crew and announced in advance for 

scheduling purposes. 

5.6 Miscellaneous 

1. Inquiries from the news media must be forwarded to the PIEDMONT VIRGINIA 

COMMUNITY COLLEGE information officer, or college president. 

Operators/Observers shall follow currently established company policy regarding 

interactions and inquiries from the media. 

2. Requests for support from third-parties will be responded to by the UAS 

coordinator. Should the request involve an immediate threat to life, or property, the 

operator is authorized to accept or decline the request. Proper policy and procedure, 

as well as FAA regulations must be followed when accepting mutual aid support 

for the UAS. 

3. Complaints or inquiries regarding UAS operations must be referred to the UAS 

coordinator. 

6. Safety 

6.1 Safety Policy 

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Unmanned Aircraft Systems Operations Manual 

6.3 Safety Officer · Operator/Observer/Coordinator 

1. In regards to safety, all members of the UAS flight crew are responsible for the 

following: 

a. Ensuring all flight operations personnel understand applicable regulatory 

requirements, standards and organizational safety policies and procedures. 

b. Observe and control safety systems by monitoring all operations. 

c. Review standards and the practices of company personnel as they impact 

operational safety. 

d. Communicate all reported safety related problems and the corrective action 

taken. If there were any in-flight problems (or learned experiences), the 

proper procedures for handling that problem should be discussed. 

e. Copy and circulate pertinent safety information. 

f. Copy and circulate emergency safety bulletins. 

g. Place any electronic copies of safety information or bulletins in a 

conspicuous location for all employees to access. 

h. It is emphasized again that safety is the responsibility of ALL members of 

the UAS unit. 

6.4 Safety Training 

1. All members shall receive training in the following subjects prior to operating the 

UAS: 

a. Company commitment to safety 

b. Company policy 

c. UAS member's role in safety 

d. Emergency safety procedures 

2. All members shall review the company safety policy and procedures on an annual 

basis and that review shall be noted in their training history. 

6.5 Medical Factors 

1. Operator and Observers shall only deploy the UAS when rested and emotionally 

prepared for the tasks at hand. 

2. Physical illness, exhaustion, emotional problems, etc., seriously impair judgment, 

memory and alertness. The safest rule is not to act as an operator or observer when 

suffering from any of the above. Members are expected to "stand down" when these 

problems could reasonably be expected to affect their ability to perform flight 

duties. 

3. A self-assessment of physical condition shall be made by all members during preflight activities. 

4. Performance can be seriously hampered by prescription and over-the-counter 

drugs. The UAS Coordinator must be advised anytime such drugs are being taken. 

If it is determined that the medication being taken could hamper an operator or 

observer, that member shall be prohibited from the deployment or exercise. 

6 
Unmanned Aircraft Systems Operations Manual 

2. In conjunction with fulfilling all training requirements for operator/observer duties, 

the new member must also become familiar with UAS operations, the aircraft and 

its equipment. 

3. Any new member who fails to successfully complete the initial training may be 

denied as a member of the U AS flight crew. 

4. Before a member can fly as an operator, they must complete at least 8 hours of 

flight training with the UAS instructors to show proficiency of the flight training 

exercises and the airframe. This must be accomplished to show their ability and 

knowledge of the UAS. 

7.5 Recurrent Training 

1. All members within the unit shall maintain proficiency in their operator/observer 

abilities. Members who do not have any documented training or flight time within 

a span of 90 days will have to show proficiency before being an operator/observer 

during a deployment or exercise. 

2. Recurrent training is not limited to actual operating/observer skills but includes 

knowledge of all pertinent VAS/aviation matters. 

3. Failure to prove proficiency can result in removal from UAS responsibilities. 

7.6 Miscellaneous 

1. Depending on the nature of the training request, all efforts are made to 

accommodate the hours of training so as little impact is made to staffing levels. 

2. All requests for training shall be approved through the member's chain of command 

and timekeeping during those training hours are marked by the U AS coordinator. 

3. Members are encouraged to attend, and forward information on FAA sponsored 

safety seminars. 

4. Training shall only be conducted at approved locations and follow the provisions 

within the approved FAA regulations. 

8. General Operating Procedures 

8.1 Request for UAS Support 

1. Requests for UAS support shall be made through the UAS coordinator who has the 

most current list of UAS operators and observers to contact. 

2. Requests for UAS support can be made at any time during the day or night. 

3. The UAS coordinator will submit a written Plan of Activities to the local FAA 

FSDO three days before the proposed mission. 

4. If a request is made for UAS support during the night, PIEDMONT VIRGINIA 

COMMUNITY COLLEGE must contact the local FAA FSDO for approval. 

8.2 Call-out Procedure 

1. The UAS coordinator will screen all initial requests to use a UAS. 

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Unmanned Aircraft Systems Operations Manual 

1. The U AS shall not be used for the purpose of random surveillance. 

2. If several separate requests for UAS support are received simultaneously, they shall 

be prioritized. 

8.4 Flight Boundaries 

1. Although there may be requests for UAS support in restricted airspace, FAA 

regulations for UAS restrict UAS deployment inside restricted airspace. 

2. At no time shall UAS support be granted inside restricted airspace without first 

obtaining permission from the local FAA FSDO and approval by local authorities. 

3. Maximum altitude shall not be set more than 400 feet per the FAA regulatory 

standards. 

4. The operator will obtain the consent of all persons involved in the mission and 

ensure that only consenting persons will be allowed within 100 feet of the flight 

operation, and this radius may be reduced to 30 feet based upon an equivalent level 

of safety determination. 

8.5 Minimum Personnel Requirements 

1. Due to the nature of the mission, the minimum personnel required on ALL missions 

will be an operator and observer. Under no circumstances will an operator attempt 

to complete a deployment alone. 

2. Although training is not considered a mission, an observer shall be used. 

8.6 Personnel Responsibilities for Deployments 

OPEN COMMUNICATION ACHIEVES SAFE OPERATIONS 

1. Operator 

a. The operator is directly responsible for, and is the final authority over the 

actual operation of the U AS. 

b. Operators have absolute authority to reject a flight based on personnel safety 

or violation of FAA regulations. No member of PIEDMONT VIRGINIA 

COMMUNITY COLLEGE, regardless of status, shall order an operator to 

make a flight when, in the opinion of the operator, it poses a risk to 

personnel or is in violation of FAA regulations. 

c. Operators are responsible for compliance with this manual, company policy 

and procedure and FAA regulations. 

d. The operator's main duty during the deployment of the UAS is to operate 

the UAS safely while accomplishing the goals of the deployment. 

e. Operators shall see-and-avoid any obstacle that will lessen safety during the 

mission. 

f. Operators shall be responsive to the requests of the observer in order to 

accomplish the deployment. 

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Unmanned Aircraft Systems Operations Manual 

5. Any physical equipment that cannot be resolved on-site, and which have an impact 

on safety or the mission, will override the deployment. These issues will be resolved 

before flight. 

9.2 Weather 

1. Before each deployment the operator/observer will ensure that he/she gathers 

enough information to make themselves familiar with the weather situation existing 

throughout the area of deployment. The operator shall utilize FAA approved 

weather resources to obtain the latest and most current weather conditions. 

2. An anemometer should be utilized in order to better estimate the wind speed and 

determine if it is within the capabilities of the airframe being flown. 

3. Operators/Observers should use the Beaufort Scale when making deployment 

decisions in regards to wind conditions. 

4. The weather conditions reported for the operation shall be recorded in the pre-flight 

checklist. 

5. The operator shall ensure that the flight will occur within FAA VFR weather 

requirements. 

9.3 Documentation 

1. Inspection and weather will be documented prior to flight within the log book. 

2. After each flight, the operator will complete a statement documenting the UAS 

operations. 

9.4 Planning 

1. The operator/observer shall familiarize themselves with all available information 

concerning the deployment including, but not limited to, the weather conditions, 

hazards, description of the incident, deployment goals, etc. 

2. Operators will ensure that the location for take-off and emergency landing is 

adequate for a safe deployment. 

a. The take-off/landing area should be clearly marked and identifiable with 

short cones. 

b. At least one emergency landing area should be identified per deployment. 

3. Operators will ensure that they are aware of their surroundings in the event that an 

emergency landing is necessary. This includes the ability to recover the UAS. 

9.5 Checklists 

1. Operators shall utilize pre-flight checklists to ensure the highest level of safety for 

deployment. 

2. Prior to flight, the flight log shall be initiated. 

12 
PRE-FLIGHT CHECKLIST* 

HULL AND PROPELLORS 

DIAn hull screws are securely fastened to the body of the UAS. 

DIAn propellers are securely fastened to the motors. 

D tfransmitters and accompanying wires are securely fastened to the hull. 

01¢amera(s), gimbal(s), and accompanying wires are securely fastened to the hull. 

Dtfhere are no loose parts, wires, screws, or extremities that can fall from the UAS. 

!operators Notes: 

SAFETY CHECK 

D [he operator performed a visual review of the area of operation. 

DIThe operator is aware of aerial obstructions (i.e., poles, structures, utility wires, trees). 

D !The operator is not within 3-miles of an airport. 

D [he operator clearly marked a take-off/landing zone with 4 orange caution cones. 

D !The operator has clearly announced that a UAS is preparing for flight. 

D jThe operator has ensured no persons or animals are near the caution zone. 

Dlweather permits the safe operation of the UAS (i.e., little to no wind, no precipitation, 

D ~f working in pairs, the second operator has a pair of binoculars to maintain line of sight I 

!operators Notes: I 

POWER TO SYSTEM 

j [ j !The battery being R!ac.ed into the U-f..S )las a f~_acizy~ . . Jll 

1 [J ~e batteries inside the RC co~troller have a sufficient ch~ =:=J. 

lr-:=JIThe£eis a spar~ UAS battery with a full charge. . . :~- Jl 

10 ~-are spare batteries for the RC controller with a full charge. ===-=:Jj j[]fu~_UAS battery is securely fastened within the UAS hull . - =:]I I LJ [The UAS powers up completely indicating a normal audible chime~pera~iMty .. ==:J 

1 il __ _j!Ailljghts ~?the UAS are operating normally. . Ji ~~~Notes: -=---ll 

RC/WIFI/FPV CONNECTIVITY 

D !There is a steady connection between the RC controller and the UAS. 

D !There is a steady connection between the video transmitter and the FPV receiver. 

D tfhe UAS is responding accurately and efficiently to RC commands. 

DIVideo equipment is responding accurately and efficiently to FPV·commands. 

D WPv OSD is operational. 

DIRe Controller is set to GPS and HL and CL modes are both turned of£ 

!operators Notes: 

UAS Operator's Signature: __________ _ Date: _______ _ 

* All UAS Operators must perform this pre-flight checklist prior to every respective flight.